Basildon is not determining its own Housing Need (OAN)

Basildon is a partner in the Thames Gateway South Essex Partnership (TGSE), an ‘established national priority area for growth’ which is largely south of the A 127 with no projects in Basildon to the north. The partnership is led by business representatives and the leaders of the six local authorities. The TGSE area is already home to more than 650,000 people, 54,000 businesses and a workforce of over 200,000. The TGSE believes our area has excellent road and rail links to the capital, the rest of the south east and other UK markets. Obviously the key players do not have to use the A 127, the A13 or the two rail links to commute to London. Local Authority plans to add around 200,000 additional residents in South East Essex lack credibility. This can be clearly seen on the SEEAGA Map.

BAG understands Basildon will accept housing figures (the Objectively Assessed Need - OAN) from TGSE. These figures will come from analysis by consultants Turley Associates who are well established supporters of the building industry. Furthermore Basildon had no input to the terms of reference for Turley Associates.

BAG understands that Basildon will not consider arguing for a Housing Target below the OAN on Green Belt grounds. Instead it will review the capacity of the current and planned Infrastructure as its only means to set a lower Housing Target. This refusal to even consider the value of our Green Belt demonstrates that our Council will ignore policy statements by government Ministers in their quest for unsustainable growth.

Basildon will not protect our Green Belt

BAG understands Basildon will review and is prepared to move its Green Belt boundaries to accommodate housing developments.Basildon Council will ignore the purpose of our Green Belt as defined in the Government’s Planning Practice Guidance, viz

to check the unrestricted sprawl of large built-up areas;

to prevent neighbouring towns merging into one another;

to assist in safeguarding the countryside from encroachment;

to preserve the setting and special character of historic towns; and

to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

This action runs counter to Ministers’ statements such as :-Eric Pickles, MP. Secretary of State for Communities and Local Government.”“If local authorities cannot meet their housing targets because of Green Belt, that is NO reason to use the Green Belt”“There will be no building on Green Belt unless there are exceptional circumstances. Failure to meet the Council's housing numbers are not 'exceptional circumstances”

Mr Pickles told The Daily Telegraph (Oct 14): “Protecting our Green Belt must be paramount. Local people don’t want to lose their countryside to urban sprawl, or see the vital green lungs around their towns and cities to unnecessary development.“The guidance will ensure councils at the heart of the reformed planning system, so councils and local people can now decide where development should - and shouldn’t - go.”

Specifically the new guidance makes clear that councils do not have to build on the Green Belt just to meet the locally set five-year housing targets.

Councils will have to “take account of any constraints such as Green Belt which indicate that development should be restricted and which may restrain the ability of an authority to meet its need”, it says.

A Government source said: “Many council planning officers are telling their councillors that they have to remove Green Belt protection when drawing up their Local Plans, in order to meet [housing] demand.

​“We are making clear that this isn’t the case, and they can take into account development restrictions – such ongoing Green Belt protection – when drawing up their Local Plans and determining how many houses they want to plan for.”

Basildon is planning development on a scale that the infrastructure cannot support

Basildon is relying on Essex CC to provide evidence that much of our infrastructure is inadequate. This evidence will be based largely on surveys & studies by Essex County Council and, presumably, consultants engaged to provide evidence that non-ECC infrastructure elements can handle the additional population’s needs.

In addition Basildon Council has no authority over those responsible for other aspects of infrastructure, such as health and transport.

​This vital evidence is being kept private until the release of the complete draft of the Local Plan. It will be impossible for residents to examine this evidence within the eight week consultation period. Given the tight restraints on local authority budgets we have serious concerns that the data used to support the new Local Plan will be outdated and therefore redundant.

Basildon has again set an excessive housing target

Legislation places certain obligations on local Councils to plan for growth. There is obvious political pressure to build more houses in the UK, but the legislation does not demand anything approaching the housing numbers set out in the last, now withdrawn, Basildon Local Plan. BAG is concerned that once again our Council will plan for excessive housing development.

It is important to recognise that central government or any government body will not impose a figure for housing needs. This is for local authorities to consider and determine.

The Framework and Guidance governing LA plan-making give Authorities considerable lee-way. There are several legitimate ways to reach an OAN. A local Authority can submit an argument for a Housing Target lower than its OAN, citing constraints such as infrastructure and Green Belt. Planning Policy and Guidance describe how continued Green Belt protection outweighs the need to meet an OAN. De-designating Green Belt is a choice and not an obligation.

​BAG’s White Paper which critiqued the withdrawn draft Local Plan. While Basildon Council may argue this is now ‘water under the bridge’ the information we are gathering suggests that the new Local Plan will again propose housing numbers that damage our Green Belt and further undermine the already overstretched infrastructure in this part of Essex.

Residents have only a short time to respond to the Consultation

Basildon has planned an eight week public consultation period for the next version of the Local Plan – the legislation specifies a minimum of six weeks. Previously, for the withdrawn plan, some contributory material was made available for public examination before the release of the draft plan. This time all documents will be held back until the start of the consultation period, so minimising the opportunity for residents to review the evidence base and the proposed Local Plan.

Basildon has not yet announced what documentation will be used to alert residents to the release of the draft Local plan or what questions will be included. Last time it asked questions about where housing land should be released without mentioning the possibility of challenging the Housing Target.

​Central Government has put pressure on Local Councils to conclude their local plans by early in 2017 by threatening to intervene.Whatever Housing Target Basildon decides is appropriate there is a risk that an independent Planning Inspector will reject the plan. On the other hand – and of greater concern to residents – an excessive housing target will impinge on the quality of life for all of us.

Residents’ responses need to be submitted and considered

The planning process rests on the professionalism of those Council Officers who are trained to plan local development. They are guided by legislation (the NPFF & Planning Practice Guidance). The public does not see or hear any guidance by the Councillors they serve, but one must assume it is given.

Officers’ work is then considered by our representatives, our elected Councillors, most of whom find themselves seriously dependent on the advice of those officers. Few have the knowledge or experience necessary to challenge what is put before them – except perhaps on political grounds. When residents’ views are expressed in response to the required consultation they are considered by the council’s officials – the same people that assembled the plan – rather than the councillors who receive only the officials’ views on the consultees arguments.

BAG has found that by learning about the planning process and finding among the Billericay residents several individuals with the capabilities to challenge the Council’s work, that the residents’ viewpoint can be professionally expressed and promoted. However we have found little desire to agree with the residents’ viewpoint and fear that the desire to have a plan, not necessarily a good plan is driving councillors.

​Lest anyone doubt that resident’s views on the Draft Local Plan may be ignored one should ask why the leader of Basildon Council has already indicated that Barratt’s wish to build on Green Belt in South Green, next to Southend Road, will be approved – this before Barratt’s have even sought any form of planning approval!

Central Government will move the goal posts before the plan is submitted

On December 7th 2015 the Government announced a consultation on National Planning Policy.

The consultation “Seeks views on specific changes to national planning policy to support delivery of new homes, including low cost homes for first time buyers”. It ends on 25th January 2016.

The scope of the consultation is:-

broadening the definition of affordable housing, to expand the range of low cost housing opportunities for those aspiring to own their new home

increasing residential density around commuter hubs, to make more efficient use of land in suitable locations

supporting sustainable new settlements, development on brownfield land and small sites, and delivery of housing allocated in plans

supporting delivery of starter homes

​These considerations are likely to have a bearing on the approach Basildon will take.

Basildon Councillors will put politics before residents’ interests

In Basildon Borough Council there is no overall majority party. The Conservatives are the largest group so they will lead, but if the other parties and independents join together in opposition to the Conservative line there will be compromise or delay.

It is quite likely that any compromise proposition from a minority party will be rejected by the others (on the lines of a Basildon versus Wickford versus Billericay contest).

If Basildon fails Central Government will impose a Housing Target

The Chancellor of the Exchequer says:-“If a council fails to produce a suitable local plan, we’ll have it done it for them.”Housing Minister Brandon Lewis says:-“Councils will have until “early 2017” to produce a local plan – or have it taken out of their hands”Dominic Veasey, Associate Director at Nexus Planning says:-“The government must therefore stand firm on its 2017 deadline. In cases where no plan has been produced the development sector would be well placed to assist the government and local communities in determining appropriate levels of growth. This sector-led analysis could be subjected to community engagement and then ratified by the Planning Inspectorate.“Can we trust an industry-led approach that lacks accountability?-----------------------------------------------------------------------------Too long a delay in reaching agreement on the Local Plan will leave Basildon’s future growth subject to consideration by Westminster. We do not know if our MPs, as our elected representatives, would speak on our behalf – or possibly push through the line taken by the local Conservatives – or if the responsible Minister(s) would decide our future growth without reference to our MPs.

We do know the outcome would be prescribed by the majority Conservative administration.

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